C borrows $250 from bank on a non-recourse loan with property as security. C then transfers the property to Z Corporation, subject to the debt, in exchange for half of Zs stock, and, as part of the same transaction, D transfers $250 in cash to Z in exchange for the other half of Zs stock. Assume the property has a fair market value of $500 prior to the borrowing and a basis of $200. Assume also that the borrowing does not have a tax avoidance purpose under 357(b). Group of answer choices

a. The transaction does not qualify under Section 351.

b. The transaction qualifies under Section 351. There is no gain or loss to recognize since no boot is received.

c. Boot is received equal to the amount of the liability of $250 so that gain must be recognized to that extent.

d. Boot is received to the extent of $50, the excess of the liability over the basis of the property. Gain must be recognized to that extent.

e. None of the above.